Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was found guilty of conspiracy to possess with the intent to distribute fifty grams or more of cocaine base, five kilograms or more of cocaine, one or more kilograms of heroin, and an undetermined quantity of marijuana, and possession with intent to distribute cocaine base, cocaine, heroin, and marijuana. Defendant received a thirty-year incarcerative sentence. Defendant subsequently filed a motion for reduction of sentence. The district court denied the motion. The First Circuit Court of Appeals vacated and remanded because the court's conclusion was not self-evident on the face of the record. In remanding, the First Circuit directed that Defendant could only be held responsible for those drugs he personally handled as well as "those that were reasonably foreseeable to him." The district court reaffirmed its ruling on remand, finding that the quantity of heroin distributed by the conspiracy was reasonably foreseeable to Defendant and in itself sufficient to support Defendant's sentence. The First Circuit reversed, holding that the district court's foreseeability finding and the drug quantity determinations underlying it were clearly erroneous. View "United States v. Candelaria-Silva" on Justia Law

After a jury trial, Defendant was convicted in the District of Massachusetts of aiding and abetting the making of a false claim against the United States in connection with his 2008 federal income tax return. Defendant appealed. The First Circuit Court of Appeals affirmed, holding (1) the district court's aiding and abetting instruction was legally correct in that it accurately conveyed the appropriate legal elements; (2) the aiding and abetting instruction did not constructively amend the indictment in violation of the Fifth Amendment; and (3) the evidence adduced at trial was sufficient to sustain Defendant's aiding and abetting conviction. View "United States v. Davis" on Justia Law

When Appellant's factoring business began experiencing serious financial troubles, Appellant allegedly defrauded a number of lenders to obtain more money to resolve her financial problems. After a government investigation, indictment, and five-day trial, a jury convicted Appellant of mail fraud. Appellant appealed her conviction, claiming that the district court erred in instructing the jury on the elements of mail fraud and that she received ineffective assistance of counsel. The First Circuit Court of Appeals affirmed, holding (1) the district court correctly focused its jury instructions on the necessary elements of a scheme to defraud and did not err in failing to give a specific unanimity instruction; and (2) Appellant failed to establish that prejudice resulted from defense counsel's performance, and therefore, she could not prevail on her ineffective assistance claim. View "United States v. LaPlante" on Justia Law

After a jury trial, Defendant was convicted in Massachusetts state courts on two counts of unarmed robbery and sentenced to concurrent terms of fifteen to twenty years' imprisonment. Defendant filed a motion for a new trial, claiming newly discovered evidence. The appeals court affirmed the convictions but remanded for an evidentiary hearing on the newly discovered evidence. Following the evidentiary hearing, the trial court denied the motion for a new trial. The appeals court affirmed. Defendant then filed a 28 U.S.C. 2254 federal habeas corpus petition in the U.S. district court, claiming ineffective assistance of counsel and violations of his right to due process. The district court dismissed the petition because it contained both exhausted and unexhausted claims. The First Circuit Court of Appeals vacated and remanded the case for reconsideration, as the record was inadequate to permit effective appellate review. View "DeLong v. Dickhaut" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to distribute 500 grams or more of cocaine. Defendant was sentenced to a ten-year mandatory minimum term of imprisonment based on the trial court's finding that the crime involved eight kilograms of cocaine. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in denying Defendant's motion to suppress evidence seized from him in Massachusetts when he left the scene of a drug deal because the agents arrested Defendant based on the strong likelihood that he had participated in criminal activity; and (2) the district court did not err in sentencing Defendant to a mandatory minimum sentence based on the court's findings as to drug quantity. View "United States v. Gomez" on Justia Law

Appellant was a probationary public employee of the Town of Smithfield, Rhode Island. The Town hired Appellant on the condition that he obtain his building official certification. After Appellant failed to obtain the certification, the Town terminated Appellant. Appellant filed a complaint against the Town and its officials, alleging that he received insufficient procedural due process in violation of the Fourteenth Amendment when his employment was terminated and that the Town violated the Rhode Island Constitution and Rhode Island Whistleblowers' Protection Act when it fired him. Defendants removed the case to federal court. The district court granted Defendants' motion for summary judgment on all counts. The First Circuit Court of Appeals affirmed, holding (1) Appellant received constitutionally adequate procedural due process; and (2) the district court acted within its discretion in reaching and resolving the state law claims after ruling against Appellant on the sole federal claim. View "Senra v. Town of Smithfield" on Justia Law

After a jury trial, Defendant was convicted of possessing child pornography. The district court sentenced Defendant to a term of imprisonment and supervised release and ordered Defendant to pay $3,150 in restitution to a woman who was depicted in some of the child pornography materials found on a laptop that Defendant sold to a pawn shop. The First Circuit Court of Appeals affirmed the conviction and the restitution award, holding (1) the evidence was sufficient to support the conviction; and (2) the district court did not err in ordering Defendant to pay restitution to the woman whose abuse at the hands of her father at age ten or eleven was depicted in video found on the laptop. View "United States v. Rogers" on Justia Law

Defendant pleaded guilty to possession of marijuana with intent to distribute and possession of a firearm by a convicted felon. At issue on appeal was whether the sentencing court erred in applying a two-level enhancement for obstruction of justice for Defendant's act of lying to federal agents in order to protect his girlfriend. The lower court found Defendant obstructed justice by making materially false statements to law enforcement officers, which significantly impeded the government's ongoing investigation and later prosecution of Defendant's criminal conduct. The First Circuit Court of Appeals affirmed, holding that Defendant's lies plainly obstructed justice, and the district court acted appropriately in applying the challenged enhancement. View "United States v. Quirion" on Justia Law

After a jury trial, Defendant was convicted of conspiring to distribute cocaine and sentenced to 120 months' imprisonment to be followed by a supervised term of release. The First Circuit Court of Appeals affirmed in all respects, holding that the district court did not err in (1) permitting a non-expert witness to identify Defendant as one of the speakers in several wiretap recordings; (2) allowing the jury to receive the transcripts of those recordings; (3) allowing the government to introduce evidence about Appellant's co-defendants' unrelated drug activity; (4) declining to give the jury Appellant's proffered race and ethnicity instruction; (5) refusing Defendant's proposed jury instruction asking the jury to determine the drug quantity attributable to Defendant; and (6) finding that Defendant was involved with five or more kilograms of cocaine. View "United States v. Diaz-Arias" on Justia Law

After a jury trial, Appellant was convicted of conspiring to commit wire fraud and committing wire fraud for his participation in a wire fraud scheme. Appellant was sentenced to a term of imprisonment followed by supervised release. The First Circuit Court of Appeals affirmed Appellant's convictions and sentences, holding (1) the evidence was sufficient to support the convictions; (2) the district court did not err in admitting files by an attorney involved in the real estate transactions that were the basis of Appellant's indictment; (3) the district court properly admitted evidence related to Appellant's involvement in two real estate transactions that were not the basis of his indictment; and (4) the district court properly sentenced Appellant. View "United States v. Appolon" on Justia Law